Privacy Policy

Privacy policy
Last updated: 29th July 2020

1 About this policy
Be Centre Foundation Limited ABN 58 128 050 037 (Be Centre, we, us) acknowledges and respects the privacy of individuals and, to this end, we will aim to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles found in that Act, as amended from time to time. This Privacy Policy sets out the way in which we will collect, use, disclose, manage and protect your personal information.
By providing your personal information to us and, if applicable, the personal information of your child and other relatives, you agree to this Privacy Policy. This Privacy Policy may change from time to time so please check our website periodically to ensure that you are aware of our current Privacy Policy.

2 Overview
We collect, hold, use and disclose personal information to carry out the functions and activities of our business. These functions and activities include:
conducting play therapy programs with children;

- conducting parent/carer support sessions;
- fundraising;
- sending electronic marketing communications;
- complying with court-issued subpoenas and other legal obligations;
- dealing with requests, queries and complaints;
- administering our business, including our website; and
- recruiting new employees.

3 What information do we collect?
If you make enquiries about our services either online or by phone, or if your child participates in a play therapy program with us, we will collect your personal information, your child’s personal information and, in some circumstances, the personal information of other relatives and individuals relevant to your child. This information may include names, phone numbers, email addresses, payment details and health information, and, in some circumstances, may also include sensitive information such as ethnicity.
We may also collect your personal information, including your name, phone number, email and/or payment details if you purchase anything through our website, volunteer with us, attend one of our fundraisers or donate to the Be Centre.
If you apply for employment with us we may collect additional personal information in relation to you including your educational and employment history and information provided by your referees.

3.1 Direct collection
The main way we collect your personal information is when you knowingly and voluntarily provide it to us, including:

- if your child is to participate in a play therapy session with us:

• when you make a general or clinical enquiry through our website or on the phone with one of our staff;
• during the initial parent consultation or review;
• during play therapy sessions with your child;
• during parent/guardian sessions with you;
• if we talk to a third party, such as another professional involved with your child, (though we will only do this with your consent);
• through any consent form or other form that we ask you to fill in; and
• through referrals from health practitioners.

- if you are a volunteer, donor or if you attend one of our fundraisers:

• when you register your interest to get involved;
• when you attend an interview with us; or
• through Working with Children Check and/or Criminal Record Check results; or

- if you:

• register or provide information on our websites;
• if you participate in a program, poll, message board, survey or questionnaire;
• subscribe to our mailing list or agree to receive our newsletters or other materials, including promotional materials;
• ask us questions or request information about our services or make a complaint; or
• apply for employment with us (either personally or through an employment agency).

3.2 Indirect collection
We may collect personal information from publicly available sources to enable us to contact supporters and sponsors. We may also collect personal information from professionals who may have important information about your child, such as a teacher, paediatrician or psychologist. However, in these circumstances we will not contact these third parties without your prior consent.
If you apply for employment with us we may collect your personal information from a recruiter engaged by us, from an employment agency you use, and from any referees you nominate.

3.3 Sensitive Information
We will not disclose sensitive information that identifies you or your child (such as information about you or your child’s health, racial or ethnic origins or political or religious beliefs) except with your specific consent or in circumstances permitted under Australian privacy legislation, for example where we are required to disclose that information by law.

3.4 Anonymity
We do not require personal information for you to gain access to our website. However, you will not be able to use certain features of our websites that require registration, enter trade promotions or receive materials such as marketing communications unless such information is provided. Further, our ability to meet our obligations to you, to provide services or process any request, complaint or application by you may be adversely affected if you do not give us the requested personal information, or if the information you give us is incomplete or inaccurate.
Furthermore, if any of your child’s personal information is to be used for any purpose other than for that of providing play therapy to your child, such as for research or academic purposes, or in reports to be sent to Play Therapy International (see section 5.1 below), the information will be de-identified.

3.5 Collection through our websites
Be Centre’s public website, https://www.becentre.org.au/, is hosted in Australia and does not use cookies. However, we may still collect your personal information through the website if you submit an enquiry form or subscribe to our newsletter.

4 Storage
Personal information collected by way of consent form, volunteer forms and clinical records are kept as hard copies in locked filing cabinets and/or in electronic form. Where an enquiry or consultation takes place over the phone or face-to-face, our staff may take notes which may subsequently be typed and kept in hard copy and/or electronic form.

5 Use and Disclosure
If you are a client with us, all of your information, including the fact that your child receives services through the Be Centre, is treated as confidential by all staff, volunteers and supervisors.

You acknowledge and consent to the use and disclosure of your personal information (and, where relevant, that of your child) in circumstances that are:

• set out in this Privacy Policy;
• explained to you at the time the information is collected from you; or
• required or permitted by law.

We may use the personal information that you give to us:

• for reasonable business purposes including record keeping and service evaluation;
• to provide you with services, newsletters or information that you have requested;
• to send you information on enhancements or functional changes to our websites or policies or other information about Be Centre; or
• for any other purpose that is stated to you at the time of collection or that you otherwise authorise.

We may disclose personal information that we collect from you to a third party:

• to meet the purpose for which it was collected, such as where we speak to other professionals involved with your child or for the purpose of carrying out Working with Children Checks;
• if we have your consent to disclose the information;
• if we are required or permitted by law to disclose the information, including for example to comply with court subpoenas and our mandatory reporting obligations to the Department of Community Justice or under the NSW Child Protection legislation;
• in the event of a merger, acquisition or any other change in ownership of all or a portion of Be Centre’s business (in which case your personal information may be transferred to the new owner so that the business can continue its operations);
• to protect the safety and security of our clients and our websites; or
• to enable us to deal with any concern, issue or complaint you have raised with us, including disclosing details of any such matter to Play Therapy International and also to professional advisors, insurers and service providers.

Be Centre allows you to tell us the way in which you would like us to use your personal information. For example, in the case of parents, we will not send you marketing materials unless you tell us you would like to receive them and, in the case of volunteers, sponsors and donors, direct marketing materials sent to you by Be Centre will give you the option to unsubscribe.

5.1 Play Therapy International
Some of our therapists are members of Play Therapy International, the international affiliate organisation of Play Therapy UK, which governs Play Therapy and oversees the Register of Play and Creative Arts Therapists. Once a year, our registered play therapists are required to send de-identified information about your child to them. The information we send includes:

- the reason your child was referred to play therapy;
- pre-therapy and post-therapy strength and difficulty scores;
- the age, gender and ethnic background of your child; and
- activities your child does during the session.

This information will be anonymised so neither you nor your child will be identified. This information is used to check the quality of the Play Therapists service, to assess how effective and efficient the service is for different types of children and to update the Play Therapy clinical evidence base.

6 Disclosure of personal information overseas
We will take reasonable steps, in the circumstances, before disclosing personal information to an overseas recipient to ensure that the overseas recipient does not breach Australian privacy laws in relation to that information.
Our donor management software, Tapestry, is hosted by Blackbaud on a server located in the United States. Blackbaud has agreed to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles to the extent that they apply to Be Centre’s services agreement with Blackbaud.
Additionally, we occasionally conduct online surveys using a variety of applications and websites that may be hosted overseas.

7 Security, Accuracy and Access
We will take reasonable technical and organisational steps to ensure that the personal information we hold is:

• accurate, complete, up-to-date, relevant and not misleading;
• stored in a secure environment; and
• protected from misuse, interference and loss as well as unauthorised access, modification or disclosure.

If any of your details change, please let us know as soon as possible by using the contact details below so we can maintain the accuracy of your personal information.

From time to time we review our security procedures to consider appropriate new technology and methods. However please appreciate that despite our best efforts, no security measure is perfect or impenetrable due to the nature of email and the internet, and we cannot guarantee the privacy or confidentiality of your personal information.

You have a right to access personal information we hold about you (other than employee records). We will comply with any valid request to access your personal information made under the Privacy Act, except where the Privacy Act or the Australian Privacy Principles allow us to refuse to do so. There is no fee for making a request to access your personal information but we may charge a fee for giving you access to your personal information in a mutually agreed format, usually by sighting the accessible information held on file.

You also have a right to ask us to correct personal information about you (other than your employee records) that is inaccurate, incomplete, out-of-date, irrelevant or misleading. If we refuse such a request to correct your personal information, we will notify you in writing of the reasons for the refusal (unless it would be unreasonable to do so) and, upon request from you, we will attach a note recording the correction that you sought to the relevant information, so that it can always be read with that information.

Any requests for access to, or correction of, your personal information should be made directly by emailing us at info@becentre.org.au. In every case where we receive a request to either provide access to, or correct, personal information concerning you, we will inform you of the action taken as a result of that request (whether or not the request is granted).

8 Contact us
If you have any questions, comments or complaints about how we handle your personal information, please contact us at info@becentre.org.au. You can also contact us at:
Be Centre
Unit10/3 Vuko Place
Warriewood
NSW 2102

We will consider and respond to any complaint notified to us within a reasonable time.
In case of dissatisfaction with a response from us you may decide to contact the Australian Information Commissioner:

Office of the Australian Information Commissioner
SYDNEY NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au